State/Prov.  : Utah

Case name    : Black v. Hennig

Case #          : No. 20100597–CA

Court             : Utah Court of Appeals

Reviewed by : Laura Morgan

Main issue     : Evidence – Bias in Child Custody Evaluation

Screenshots from internet social networking site (Facebook) were admissible in child custody action to demonstrate that clinical psychologist who conducted the custody evaluation and father’s attorney frequently contacted one another and that they had a long‑standing friendship, which, if established, would demonstrate bias or a motive to testify differently than would otherwise be the case.


Laura Morgan is a Family Law Consultant. Laura is available for consultation, brief writing and research on family law issues throughout the country. She can be reached through her Web site.